Fiduciary Counselors

No. The firm is a non-discretionary consultant and named fiduciary, not an investment manager. It constructs investment policy, selects and monitors third-party managers across public and private markets, but never takes custody of client assets or makes buy/sell decisions on behalf of plans. This structural separation is the foundation of its conflict-free model.

Fiduciary Counselors accepts co-fiduciary status under ERISA Section 3(21), meaning it shares fiduciary liability with the plan sponsor for the investment advisory functions it performs. This includes recommending investment managers, monitoring performance, and advising on plan governance. The firm does not act as a 3(38) investment manager with discretionary authority.

The firm operates exclusively on a hard-dollar, fee-for-service basis. It accepts no revenue-sharing, 12b-1 fees, placement agent commissions, or soft-dollar compensation from investment managers — a rarity among institutional consultants, many of whom maintain supplementary broker-dealer operations or accept manager-paid conference sponsorships.

The firm advises a cross-section of ERISA-governed plans: corporate defined benefit and defined contribution plans, Taft-Hartley multiemployer trust funds, public retirement systems, and non-qualified deferred compensation programs. Its client base is exclusively institutional.

Anne L. Becker was promoted to Chief Compliance Officer in January 2024 (per the firm's official communications). The CCO function is responsible for monitoring Department of Labor and SEC regulatory developments that affect ERISA plan fiduciaries and the firm's own advisory practices.